Joseph Kindler was convicted of murder in the state of Pennsylvania, and the jury recommended death.

The trial court denied these requests, citing Pennsylvania fugitive forfeiture laws.

Kindler then requested federal habeas corpus relief and the District Court granted it, determining that the state fugitive forfeiture law did not provide adequate basis to bar federal review.

On remand for further consideration of the issue, the Third Circuit determined that the state court had applied its fugitive forfeiture rule as though it were mandatory, which had not been the rule at the time of Kindler's escape from prison.

It reinstated the grant of habeas relief overturning Kindler's death sentence[1] and he was subsequently resentenced to life without parole.